# FAA Exemption Rulemaking Section 333 Of The FAA Reform Act Part 11

Air Renditions Videography 1294 Lynwood Dr. Novato, CA 94945 415-895-6634 www.airrenditions.com

February 23, 2015

Attention: United States S ecretary of Transportation Mr. Anthony R Foxx 1200 New Jersey Ave., SE Washington, DC 20590

Re: Exemption Request Section 333 of the FAA Re form Act and Part 11 of the Federal Aviation Regulations from 14 CFR 45.23(b) ; 14 CFR Part 21; 14 CFR 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.409 (a) (2); 91.417 (a) & (b)

Dear Mr. Secretary,

Pursuant to Section 333 of the FAA Modernizati on and Reform Act of 2 012 (the Reform Act) and 14 CFR Part 11, Air Renditions Videography, a research deve loper and operator of Small Unmanned Aircraft Systems (“sU ASs)” equipped to conduct aeria l photography for industrial, motion picture, and television industry for scri pted closed set filming, hereby applies for an exemption from the listed Federal Aviation Regulati ons (“FARs”) to allow commercial operationof its sUASs (both Fixed-wing & Multi-Rotor), so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA as required by Section 333

. 1

As described more fully below, the requested exemption would permit the operation of small, unmanned and relatively inexpensive sUAS under c ontrolled conditions in airspace that is 1) limited 2) predetermined 3) controlled as to acces s and 4) would provide safety enhancements to the already safe operations in the industrial, f ilm, and television production community presently using conventional and unmanned aircraft. Approval of this ex emption would thereby enhance safety and fulfill the Secretary of Transportation’ s (the FAA Administrator’s ) responsibilities to “...establish requirements for the safe operation of su ch aircraft systems in the national airspace system.” Section 333 (c) of the Reform Act

1 The conditions proposed by the applicant ar e drawn from Order 8900.1 CHG 0, Volume 3, Chapter 8- Issue a Certificat e of Waiver for Motion Pict ure and Television Filming.

The name and address of the applicant is: Air Renditions Videography 1294 Lynwood Dr. Novato, CA 94947 Attn: Tim Thompson Rich Galagaran Phone: 415-895-6634 Email: richgalagaran@airenditions.com timthompson@airrenditions.com

Regulations from which the exemption is requested:

14 CFR Part 21 14 CFR 45.23 (b) 14 CFR 61.113 (a) & (b) 14 CFR 91.7 (a) 14 CFR 91.9 (b) (2) 14 CFR 91.103 14 CFR 91.109 14 CFR 91.119 14 CFR 91.12114 CFR 91.151 (a) 14 CFR 91.203 (a) & (b) 14 CFR 91.405 (a) 14 CFR 407 (a) (1) 14 CFR 409 (a) (2) 14 CFR 417 (a) & (b)

This exemption application is expressly submitte d to fulfill Congress’ goal in passing Section 333 (a) through (c) of the Reform Ac t. This directs the Secretary of Transportati on to consider whether certain unmanned aircraft systems may ope rate safely in the national airspace system (NAS) before completion of the rulemaking requi red under Section 332 of the Reform Act. In making this determination, the Secretary is re quired to determine which types of UASs do not create a hazard to users of the NAS or the public or pose a threat to national security in light of the following:

 The UAS’s size, weight, speed, and operational capability:

 Operation of the UAS in close proximity to airports and pop ulated areas; and

 Operation of the UAS within Visual Line of Sight (VLOS) of the Pilot and Observers.

Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretar y shall establish requirements for the safe operation of such aircraft in the national airspace system.” Id. § 333 (c) (emphasis added)

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The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority by its terms in cludes exempting civil aircraft, as the term is defined under § 40101 of the Act, that includes sUASs, from the re quirement that all civil aircraft must have a current airworthiness certificate. The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any sections 44702-44716 of this title if the Administrator finds the exemption in the public interest. 49 U.S.C. §44704; 14 CFR §91.203 (a) (1).

1 Applicant interprets this provision to place of the duty on the Administrator to not only process applications for exemptions under section 333, but for the Administrator to craft conditions herein for the safe operation of the UAS, if it should be determined th at the conditions set forth herein do not fulfill the statutory requirements for approval.Air Renditions Videography’s sUASs are rotorcra ft and fixed-wing airc raft, weighing 55 or fewer lbs. including sensor payload. They operate their rotorcraft, under normal conditions at a speed of no more than 20 knots and have the capabi lity to hover, and move in the vertical and horizontal plane simultaneously. They operate th eir fixed-wing aircraft, under normal conditions at a speed of no more than 20 knots and primarily have the flight characteristics of traditional airplanes. They will manually operate only in VL OS and will operate only within the sterile area described in the Confidential: Flight Oper ations Manual (FOM) attached as Exhibit 1 (hereinafter “the Manual” )

. 3 Adherence to the Manual will insu re that the sUAS will “not create a hazard to the national airspace system or the public.” 4
Given the small size and weight of the sUAS i nvolved and the restricted sterile environment within which they will operate, the applicant fa lls squarely within that zone of safety (an equivalent level of safety) in which Congre ss envisioned that the FAA must, by exemption, allow commercial operations of sUASs to commen ce immediately. Also due to the size of the sUASs and the restricted areas in which the relevant sUAS will operate, approval of the application presents no national security issue. Given the clear direction in Section 333 of the Reform Act, the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety, surrounding the propo sed operations, and signi ficant public benefit, including enhanced safety, reduc tion in environmental impacts, including reduced emissions associated with allowing UASs for movie and te levision operations, the gr ant of the requested exemptions is in the public interest. Accordingl y, the applicant respectfully requests that the FAA grant the requested exemption without delay.

2 The Flight Operation Manual is presented as an applicant Confidential document under 14 CFR 11.35 (b) as the entire manual contains proprietary methods and information that the applicant has not and will not share with others. The manual reflects learne d experiences, methods, operating conditions, and procedures that are not available to the public and are protected from release under the Freedom of Information Act 5 USC 552 et.seq.

4Reform Act Section 333 (b)AIRCRAFT AND EQUIVALENT LEVEL OF SAFETY

The applicant proposes that the ex emption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to opera tions under the current regulator structure because the proposed ope rations represent a safety enha ncement to the already safe movie and television filming operations conducted with conventional aircraft. These limitations and condition to which Air Renditions Vi deography agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1. The sUAS will weigh less than 55 lbs.

2. Flights will be operated manually within visual line of sight (VLOS) of the Pilot and aircrew (Spotter / Observer, Camera / Sensor Operator).
3. Maximum total flight time for each operationa l flight will be 30 minutes. Flights will be terminated at 25% battery power reserve s hould that occur prior to the 30 minute limit.
4. Flights will be operated at an altitude of no more than 400 feet AGL or, not more than 200 feet above an elevated platform from whic h airborne data collection is planned.
5. Minimum two (2) man crew for each sUAS opera tion will consist of the Pilot and Spotter / Observer. In most cases the third aircrew member will serve as the Camera / Sensor Operator.

6. The sUAS Pilot will be an FAA licensed airman with at least a private pilot’s certificate and third class medical. The Camera / Sensor Operat or and Spotter (Observer) will hold at least a third class medical.

7. The sUASs Pilot will serve as Pilot in Command (PIC). If a pilot certificate holder other than the sUAS Pilot, who possess the necessary PIC qualificat ions, is also presen t on set (i.e. the Aerial Coordinator), that person can also be designated as PIC.
8. The sUASs will only operate w ithin a confined “Sterile Area” as defined in the Manual. Section D of the Manual requires the establishm ent of a “Security Perimeter” for the flight operations areas.

A pre-flight briefing wi ll be conducted in regard to the planned sUAS operation prior to each day’s production activities. It will be mandatory that all personnel who will be performing duties within the boundaries of the safety pe rimeter be present for this briefing.10. The Operator will file a FAA Form 7711-1, or its equivalent, as modified in light of the requested exemption, with the appropriate Flight Standards Dist rict Office (FSDO).
11. The Operator will obtain the c onsent of all persons involved in the filming and ensure that only consenting persons will be allowed within 100 feet of the flight operation, and this radius may be reduced to 30 feet based upon an equivale nt level of safety determination, as required by Appendix A.3 of the Manual. With the advanced pe rmission of the relevant FSDO, operations at closer range can be approved.

12. The Operator will submit a written Plan of Ac tivities to the FSDO three (3) days before the proposed shoot as required by Section E of the Manual.
13. Pilot, Camera Operator, and Spotter (Observer) will have been trained in operation of sUAS generally and received up-to-date information on the particular s UASs to be operated as required by Section J and Section 2. B of the Manual.
14. Spotter (Observer) and Pilot wi ll at all times be able to communicate by voice, radio, and/or
text.
15. Written and/or oral permission from the re levant property holders will be obtained.

16. All required permission s and permits will be obt ained from territorial, state, county or city jurisdictions, including local law enforcement, fi re, or other appropriate governmental agencies.

17. If the sUASs loses communications or loses its GPS signal, the sUASs will have capability to return to a pre-determined location w ithin the Security Perimeter and land.
18. The sUASs will have the capability to abort a flight in case of unpredicted obstacles or emergencies.

14 CFR Part 21, Subpart H: Airw orthiness Certificates 14 CFR §91.203 (a) (1)

Subpart H, entitled Airworthine ss Certificates, establishes the procedural requirements for the issuance of airworthiness cer tificates as required by FAR §91.203 (a) (1). Given the size and limited operating area associated with the aircraft to be utilized by the Applicant, an exemption from Part 21 Subpart H meets the requirements of an equivalent level of sa fety under Part 11 andSection 333 of the Reform Act. The Federal Aviation Act (49 U.S.C. §44701 (f)) and Section 333 of the Reform Act both authorize the FAA to exempt aircraft from the requirement capability, and proximity to airpor ts and populated areas of the part icular UAS. In all cases, an analysis of these criteria de monstrates that the UAS opera ted without an airworthiness certificate, in the restricted environment and unde r the conditions proposed will be at least as safe, or safer, than a conventional aircraft (fixed-wing or rotorcra ft) operating with an airworthiness certificate without the restrictions and conditions proposed.
The sUASs to be operated hereunder is less than 55 lbs. fully loaded, carr ies neither a pilot nor passenger, carries no explosive materials or fl ammable liquid fuels, and operates exclusively within a secured area as set out in the Manual. Unlike other civil aircraft, operations under this exemption will be tightly controlled and monito red by both the Operator, pursuant to safety requirements, and under the requirements and in compliance with local public safety requirements, to provide security for the area of operation as is now done with conventional filming. The FAA will have advance notice of a ll operations. These safety enhancements, which already apply to civil aircraft operated in connection with motion picture and television production, provide a greater degr ee of safety to the public and property owners than conventional operations conducted with airworthin ess certificates issued under 14 C.F.R. Part 21, Subpart H. Lastly, application of these same cr iteria demonstrates that there is no credible threat to national security posed by the UAS, du e to its size, speed of operation, location of operation, lack of explosive materials or flam mable liquid fuels, and inability to carry a substantial external load.

Page Eight 14 CFR §45.23 (B): Marking of the Aircraft

The regulation requires:

When marks include only the Roman capital letter “N” and the registratio n number is displayed on limited, restricted or light-sport category aircraft or experiment al or provisionally certificated aircraft, the operator must also disp lay on that aircraft near each entr ance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more th an 6 inches high, the words “limited,” “restricted”, “light-sport,” “experiment al,” or “provisional,” as applicable.
Even though the sUASs will have no airworthine ss certificate, an exemption may be needed as the sUASs will have no entrance to the cabin, cockpit or pilot station on which the word “Experimental” can be placed. Given the size of the sUAVs, two-inch lettering will be impossible. The word “Experimental” will be placed on the fuselage in compliance with §45.29 (f).The equivalent level of safety will be provided by having the sUAVs marked on its fuselage as required by §45.29 (f) where the Pilo t, Spotter (Observer) and ot hers working with the sUAVs will see the identification of the UAS as “Expe rimental.” The FAA has issued the following exemptions to this regulation to Exemptions Nos. 10700, 8738, 10167 and 10167A.

14 CFR §61.113 (a) & (b): Private Pilot Privileges and Limitati ons - Pilot in Command (PIC)
Sections 61.113 (a) & (b) limit priv ate pilots to non-commercial operations. Because the UAS will not carry a pilot or passengers, the proposed op erations can achieve th e equivalent level of safety of current operations by requiring the PIC ope rating the aircraft to have a private pilot’s license rather than a commercial pilot’s license to operate this small UAS. Unlike a conventional aircraft that carries the pilot and passengers, the sUAS is remotely contro lled with no living thing on board. The area of operation is controlled an d restricted, and all fl ights are planned and coordinated in advance as se t forth in the Manual. The le vel of safety provided by the requirements included in the Manual exceeds th at provided by single individual holding a commercial pilot’s certificate operating a conventional aircraft . The risks associated with commercial operations contemplat ed by Part 61 when drafted, th at allowing operations of the sUAS as requested with a private pilot as the PIC exceeds the present level of safety achieved by 14 CFR §61.113 (a) & (b).

14 CFR §91.7 (a): Civil Ai rcraft Airworthiness

The regulation requires that no person may operate a civil aircraft unle ss it is in airworthy condition. As there will be no ai rworthiness certificat e issued for the aircraft, should this exemption be granted, no FAA regulatory standa rd will exist for determ ining airworthiness. Given the size of the aircraft and the requireme nts contained in the Manual for maintenance and use of safety check lists prior to each flight, as set forth in Sections J, L and Q, an equivalent level of safety will be provided.

14 CFR §91.9 (b) (2): Civil Aircraft Flight Manual in the Aircraft

Section 91.9 (b) (2) provides:

No person may operate a U.S.-re gistered civil aircraft ...2) For which an Airplane or Rotorcraft Flight Manual is not required by §21.5 of this chapter, unless there is available in the aircraft a curren t approved Airplane or Ro torcraft Flight Manual, approved manual material, markings, and pl acards, or any combination thereof.
The sUAS, given its size and configuration has no ability or place to carry such a flight manual on the aircraft, not only because there is no pi lot on board, but because there is no room or capacity to carry such an item on the aircraft.
The equivalent level of safety will be mainta ined by keeping the flight manual at the ground control point where the pilot flying the sUAS will have immediate access to it. The FAA has issued the following exemptions to this regulation: Exemption Nos. 8607, 8737, 8738, 9299, 9299A, 9565, 9565B, 10167, 10167A 10602, 32827, and 10700

14 CFR §91.103: Preflight Action

This regulation requires each pilot in command to take certain actions before flight to insure the safety of flight. As FAA approved rotorcraft flight manuals will not be provided for the aircraft an exemption will be needed. An equivalent level of safety will be provided as set forth in Sections J and K of the Manual. The PIC will take all actions including reviewing weather, flight battery requirements, landing and takeoff dist ances and aircraft performance data before initiation of flight.

14 CFR §91.109: Flight Instruction

Section 91.103 provides that no person may operate a civil ai rcraft (except a manned free balloon) that is being used for flight instructi on unless that aircraft has fully functioning dual controls. SUASs and remotely piloted aircraft, by their design do not have fully functional dual controls. Flight control is accomplished through th e use of a control box that communicates with the aircraft via radio communications. The FAA has approved exemptions for flight training without fully functional dual controls for a numbe r of aircraft and for flight instruction in experimental aircraft. See Exemptions Nos. 5778K & 9862A. The equivalent level of safety provided by the fact that aircraft.

14 CFR §91.119: Minimum Safe AltitudesSection 91.119 establishes safe altitudes for opera tion of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the mi nimums prescribed, provided the person operating the helicopter complies with any route or altitude s prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a fixed-wing or rotorcraft requests authority to operate at altitudes up to 400 ft. AGL, or not more than 2 00 ft. above an elevated platform from which filming is planned, an exemption may be needed to allow such operations. As set forth herein, except for the limited conditions stated in the Manual, the sUASs will never operate at higher than 400 ft. AGL. It will however be operated in restricted area with security perimeter, where buildings and people will not be exposed to operations without their pre-obtained consent.

The equivalent level of safety will be achieved given the size, weight, speed of the sUASs as well as location where it is ope rated. No flight will be taken without the permission of the property owner or local official s. Because of the advance noti ce to the property owner and participants in the filming activity, all affected individuals will be aware of the planned flight operations as set forth in Section K of the Manual. Compared to flight opera tions with aircraft or rotorcraft weighing far more than the maximu m 55 lbs. proposed here in and the lack of flammable fuel, any risk associated with thes e operations is far less than those presently presented with conventional aircraft operating at or below 500 ft. AGL in the movie industry. In addition, the low-altitude operations of the sUAS s will ensure separation between these small sUASs operations and the operations of conventional aircraft that must comply with Section 91.119.

14 CFR §91.121: Altimeter Settings

This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the el evation of the departure ai rport or an appropriate altimeter setting available before departure.” As the sUAS may not have a barometric altimeter, but instead a GPS altitude read out, an exemption may be needed. An equivalent level of safety will be achieved by the operator, pursuant to th e Manual and Safety Check list, confirming the altitude of the launch site shown on the GPS altitude indicator before flight.

14 CFR §91.151 (a): Fuel Requirement s for Flight in VFR ConditionsSection 91.151 (a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wi nd and forecast weather conditions ) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed – (1) During the day, to fly after that for at least 30 minutes; or (2) At night, to fly after that for at least 45 minutes.”

The battery powering the sUAS provides approxim ately 40 minutes of powered flight. To meet the 30 minute reserve requirement in 14 CF R §91.151, sUASs flights would be limited to approximately 10 minutes in length. Given the lim itations on the UAS’s proposed flight area and the location of its proposed operatio ns within a predetermined area, a longer time frame for flight in daylight or night VFR conditions is reasonable.

Applicant believes that an exemption from 14 CFR §91.151 (a) falls within the scope of prior exemptions. See Exemption 10673 (allowing Lockh eed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives wh o have signed waivers will be allowed, with less than 30 minutes of reserved fuel, does not engender th e type of risks that Section 91.151 (a) was intended to alleviate gi ven the size and speed of the small UAS. Additionally, limiting sUAS flights to 10 minutes would greatly re duce the utility for which the exemption will be granted.

Applicant believes that an equivalent level of safety can be achieved by limiting flights to 30 minutes or 25% of battery power whichever happen s first. This restriction would be more than adequate return the sUAS to its planned landi ng zone from anywhere in its limited operating

area.
Similar exemptions have been granted to ot her operations, including Exemptions 2689F, 5745, 10673, and 10808.

14 CFR §91.203 (a) and (b): Carrying Civil Aircraft Certificat ion and Registration
The regulation provides in pertinent part:

(a) Except as provided in §91.715, no person may operate a civil aircraft unle ss it has within it the following:
(1)An appropriate and current airworthine ss certificate...(b) No person may operate a civil aircraft unless the airworthine ss certificate required by paragraph (b) of this section or a special flight authorization issued unde r §91.715 is displayed at the cabin or cockpit entrance so that it is legible to pa ssengers or crew.
The UAS fully loaded weighs no more than 55 lbs. and is operated without an onboard Pilot. As such, there is no ability or place to carry certif ication and registration documents or to display them on the sUAS.
An equivalent level of safety will be achieved by keeping these documents at the ground control point where the Pilot flying the s UAS will have immediate access to them, to the extent they are applicable to the sUAS. The FAA has issued numerous exemptions to this regulation. A representative sample of other exceptions in cludes Exemption Nos. 9565, 9665, 9789, 9789A, 9797, 9797A, 9816A, and 10700.

14 CFR §91.405 (a); 407 (a) (2); 417 (a ) & (b): Maintenance Inspections

These regulations require that an aircraft operator or owner “shall ha ve that aircraft inspected as prescribed in subpart E of this part and shall between required inspections , except as provided in paragraph © of this section, have discrepancies repaired as prescribed in Part 43 of this chapter...,” and others shall inspect or mainta in the aircraft in compliance with Part 43.

Given that these section and Part 43 apply only to aircraft with an airworthiness cert ificate, these sections will not apply to the applicant. Maintenance will be accomplished by the operator pursuant to the flight manual and operating handbook as referenced in the Manual. (See Sections L and Q) An equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload a nd operate only in restri cted areas for limited periods of time. If mechanical issues arise the UAS can land immediately and will be operating from no higher than 400 ft. AGL. As provided in the Manual, the operator will ensure that the UAS is in working order prior to initiating flig ht, perform required maintenance, and keep a log of any maintenance performed. Moreover, the operator is the person most familiar with the aircraft and best suited to ma intain the aircraft in an ai rworthy condition to provide the equivalent level of safety.
********* Pursuant to 14 CFR Part 11, the following summar y is provided for publication in the Federal Register, should it be determined that publication is needed: Applicant seeks an exemption from the following rules:14 CFR § 21, subpart H; 14 CFR § 45.23 (b); 14 CFR § 61.113 (a) & (b); 91.7 (a); 91.9 (b) (2); 91.103 (b); 91.109; 91.119; 91.121; 91.151 (a); 91.203 (a) & (b); 91.40 5 (a); 91.407 (a) (1); 91.409 (a) (2) and 91.417 (a) & (b) to operate comme rcially a small unmanned vehicle (55lbs or less) in industrial, motion pi cture and television operations.

Privacy

All flights will occur over privat e or controlled access property with the property owner’s prior consent and knowledge. Image capture of people will rarely take place, but in the event they are, they will have consented prior to being filmed or otherwise have agreed to be in the area where data collection will take place.

Airborne Image Capture (Day & Night)

With regard to airborne filming, Air Renditions Videography adheres to all FAA regulations. Further AWI airborne teams operate under the prin cipals of: Safety First, Quality Assurance, Accountability, Reporting, and Training. When appr oved by the FAA it is AWI’ mandate to treat all sUASs operations the exact same as that of conventional aircraft.

Approval of exemptions allowing commercial oper ations of sUASs in the film industry will enhance safety by reducing risk. Conventional film operations, using jet or piston powered aircraft, operate at extremely low altitudes just fe et from the subject being filmed and in extreme proximity to people and structures ; and present the risks associated with vehicles that weigh in the neighborhood of 4,000lbs., carryi ng large amounts of Jet A or ot her fuel (193 gallons for jet helicopter shown below). Such aircraft must fly to and from film location. In contrast, a sUAS weighing fewer than 55lbs. (Inspire 1 travel case shown below) and powered by batteries eliminates virtually all of the risk given the substantial reduced mass and lack of combustible fuel carried on board. The sUAS is typically transported to the lo cation via auto or cargo van in a medium sized case and is never flown to set. The sUAS will carry no passengers or crew and, therefore, will not expose them to the risks associated with manned aircraft flights.

INSPRIRE 1 – SINGLE CASE W/ DUA L CONTROLLERS ASTAR 355 W/IR SENS OR MOUNTED ON TYLER SIDEMOUNT

The operation of small UASs, weighting less than 55lbs., conducted in th e strict conditions outlined above, will provide an equivalent level of safety supporting the grant of the exemptions requested herein, including ex empting the applicant from the requirements of Part 21 and allowing commercial operations. Thes e lightweight aircraft operate at slow speeds, close to theground, and in a sterile environment and, as a resu lt, are far safer than ground than conventional operations conducted with turbine helicopters operating in clos e proximity to the ground and people.

DAMAGE ASSESSMENT - CELLULAR TOWER POWER LINE - HIGH VOLTAGE SUB-STATION
The primary market of interest for AWI utilizing sUASs is the visual inspections of telecommunications towers and se condary is power lines. To simulate sUAS aircraft flying at below 400 feet AWI has conducted manned aircraft data collections utilizing gyro-stabilized systems (i.e., CineFlex, Wescam) with standard l ong telephoto lenses. In th e cellular tower sector it is estimated the use of sUAS aircraft will re duce hazardous tower climbs by as much as forty percent (40%). Aside from reducing the number of physical climbs, the ut ilization of sUAS will dramatically lower the use of cranes and lifts, which also pos e dangerous conditions for build and repair personnel. In a number of instances, inspector s just need to get “eyes on” the tower top assemblies to look for specific deficiencies. With regard to power lines when climbers are sent in the power must be deferred. The use of s UAS may allow these industries to fill in the data gaps where traditional aircraft are current ly restricted. In addition AWI is conducting engineering research with local universities addressi ng a number of sUAS concerns (i.e., RF shielding, flight control range).

It is anticipated that the airborne image cap ture process will be accomplished in both day and night environments. Currently, c onventional aircraft are flown in highly populated and/or urban areas, with turbine powered helicopters. The gr ant of this exemption request will provide improved safety in both day and night operations. To capture the highest quality of resolution the majority of airborne data collections w ill take place during the 10:00am – 4:00pm window. There may be night operations conducted where infrared sensors will be deployed. If such operations are required the ground facilities and the subject tower assemblies may require additional lighting so that visibility is as though it was conducted during daylight hours.
Summary

Satisfaction of the criteria pr ovided in Section 333 of the Re form Act of 2012 – size, weight, speed, operating capabilities, proximity to air ports and populated areas and operation within visual line of sight and national s ecurity – provide more than ade quate justification for the grant of the requested exemptions allowing comme rcial operation of applicant’s sUAS in the industrial, motion picture and television producti on industry pursuant to the Manual appended hereto. AWI is eagerly standing by to support th e FAA and sUAS community in its quest toestablish proper regulations and protocols for the safe introduction of unmanned aircraft into the national airspace.

Sincerely,

Rich Galagaran CEO Tim Thompson CTO

Air Renditions Videography 1294 Lynwood Dr. Novato, CA 94947 415-895-6634 www.airrenditions.com